Madhya Pradesh High Court Issues Show-Cause Notice To Advocate Over Continued Practice Despite Contempt Conviction

The Gwalior Bench of the Madhya Pradesh High Court has issued a show-cause notice to an advocate after expressing serious concern over his continued appearance before the court despite a subsisting conviction for criminal contempt and alleged violation of the High Court’s rules governing legal practice.

The development came while the court was hearing a bail application filed by an accused in a criminal case. Although the bail plea itself was ultimately rejected considering the seriousness of the allegations and the stage of investigation, the court’s order drew particular attention to the conduct and eligibility of the advocate representing the applicant.

Justice Milind Ramesh Phadke, while passing the order, noted that the advocate had earlier been held guilty of criminal contempt by the High Court in April 2024. The conviction had subsequently attained finality after the Supreme Court declined to interfere with the finding of guilt, although it reduced the quantum of costs imposed by the High court.

Referring to the earlier contempt proceedings, the High court reproduced extracts from the judgment which recorded that the advocate’s apology at the time had appeared to be merely an attempt “to save the skin,” noting that the language used in his pleadings and complaints had contained repeated allegations against judges despite several warnings. The court had therefore found him guilty of criminal contempt under Section 2(c) of the Contempt of Courts Act, 1971 and imposed a fine along with substantial costs.

The court further noted that although the Supreme Court later reduced the cost imposed by the High Court from ₹5 lakh to ₹1 lakh, it did not interfere with the finding of guilt. The High Court emphasised that the conviction for criminal contempt therefore continues to subsist.

The court observed that there was nothing on record to show that the advocate had taken steps to purge the contempt. It clarified that mere reduction of the fine by the Supreme Court cannot be treated as exoneration or as purgation of contempt under law.

The bench also recorded its dissatisfaction with the advocate’s conduct during the bail hearing. According to the order, the advocate repeatedly attempted to divert the proceedings away from the bail issues and raised matters already settled by judicial orders. The court further noted that his remarks during arguments were insinuatory and provocative and went beyond the permissible limits of advocacy.

“The tone, tenor, and manner of submissions reflected a deliberate attempt to intimidate and influence the Court, rather than to responsibly argue the merits of the case,” the order observed.

The bench underscored that advocacy is not merely a right to argue zealously on behalf of a client but also carries a duty to maintain dignity and decorum in judicial proceedings. It noted that the advocate’s conduct showed a lack of restraint and fell short of the ethical standards expected from an officer of the court.

The court also referred to several Supreme Court judgments affirming that constitutional courts possess inherent powers to regulate the appearance of advocates in order to maintain discipline and preserve the dignity of the judicial process.

In view of these circumstances, the High court directed its registry to issue a show-cause notice to the concerned advocate asking him to explain under what authority he was continuing to appear and plead before the court without demonstrating compliance with Rule 16 of the Practice Rules.

Additionally, the court directed that a notice be issued to the State Bar Council seeking information on the steps taken, if any, following the earlier contempt order which had been affirmed by the Supreme Court.

The notices have been directed to be issued within seven days and made returnable within four weeks. The matter will next be listed in April 2026 for further consideration.

Case Title: Munendra Singh v. The State of Madhya Pradesh

Date of Order: February 23, 2026

Bench: Justice Milind Ramesh Phadke